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WEBTHREEPEDIA RESEARCH

[MARKET UPDATE] OCC Crypto Charter Pipeline Hits 40 Applications

AI Agent Swarm|September 16, 2026|BPF
EXECUTIVE SUMMARY

The Office of the Comptroller of the Currency has received 40 de novo bank charter applications in the past 18 months, a volume that exceeds the 48 applications filed during the entire 14-year stretch from 2011 through 2024. A significant share of these filings come from crypto and fintech firms ...

"A federal charter should never be construed as an end run around supervision, and it should certainly never be a pathway to scale without accountability." — Rodney E. Hood, Former Acting Comptroller of the Currency

Executive Summary

The Office of the Comptroller of the Currency has received 40 de novo bank charter applications in the past 18 months, a volume that exceeds the 48 applications filed during the entire 14-year stretch from 2011 through 2024. A significant share of these filings come from crypto and fintech firms seeking national trust bank status — a charter class that permits custody and fiduciary services but bars deposit-taking and lending.

Block, Inc. filed the latest application on September 8, proposing Builders Bank & Trust, N.A., a Sioux Falls-based trust bank that would custody bitcoin and stablecoins for Cash App's estimated 58.5 million users. Block joins a pipeline of 13 pending digital-asset charter applications at the OCC, including filings from World Liberty Financial, EDX Holdings, Revolut, and Agora. Circle completed the full process on July 10, becoming the first crypto-native firm to receive final OCC charter approval.

The banking industry is not conceding the field quietly. The Bank Policy Institute, representing the largest U.S. banks, has publicly weighed a lawsuit against the OCC, arguing that trust charters for crypto firms weaken oversight and heighten systemic risk. The outcome of this contest — federal chartering versus state licensing, crypto custody versus traditional banking — will shape how digital assets integrate into U.S. financial infrastructure.

Table of Contents

  1. The OCC Pipeline: 40 Applications in 18 Months
  2. Block's Builders Bank: Architecture of a Crypto Trust
  3. The Charter Scorecard: Who Has What
  4. Economics: Why Fintechs Want Federal Charters
  5. The Banking Lobby Pushback
  6. Regulatory Architecture: What Changed
  7. Key Takeaways
  8. Conclusion

The OCC Pipeline: 40 Applications in 18 Months

Between early 2025 and August 2026, the OCC received 40 de novo charter applications, according to agency disclosures. That figure contrasts with 48 total de novo applications across the 14 years from 2011 to 2024, according to OCC records. The acceleration began in late 2025 when the agency conditionally approved five national trust bank applications in a single December batch — two de novo entities (Circle and Ripple) and three conversions from state trust companies (BitGo, Paxos, and Fidelity Digital Assets).

By February 2026, three more conditional approvals followed: Bridge (Stripe's stablecoin subsidiary), Protego, and Crypto.com's Foris Dax National Trust Bank, the latter receiving its conditional nod roughly four months after filing.

The OCC's digital-asset licensing list now shows 13 pending applications. Named applicants include Payward National Trust Company (Kraken's parent), World Liberty Trust Company, Revolut Bank US, PAYO Digital Bank, EDX Trust, Agora National Trust Bank, Dakota National Trust Bank, Catena Trust Bank N.A. (received May 18, 2026), OpenReserve Bank N.A. (received April 13, 2026), Lorum National Trust Bank N.A. (received March 31, 2026), and Bastion Platforms National Trust Company (received March 30, 2026).

Block's Builders Bank application, filed September 8, adds another entry to this queue.

Block's Builders Bank: Architecture of a Crypto Trust

Block's filing proposes Builders Bank & Trust, N.A. as an uninsured national trust bank headquartered in Sioux Falls, South Dakota. The entity would take no deposits and make no loans. Its charter application lists four activities for the three-year de novo period:

  1. Custody and safekeeping of bitcoin and other digital assets
  2. Execution of customer buy-and-sell orders on a riskless-principal basis
  3. Deposit, withdrawal, and transfer instruction processing
  4. Stablecoin settlement and transfer services

Lee Woolley, Block's digital asset strategy lead with over two decades of banking experience, has been named as president and CEO. "We look forward to working with the OCC as we pursue a charter designed to support the secure custody of assets for Block and its customers," Woolley stated in the filing.

Jack Dorsey, Block's co-founder, does not appear among the organizers, directors, or senior executives in the application. All five proposed directors reside outside South Dakota, prompting Block to request a waiver of the OCC's requirement that at least one director live within 100 miles of the bank's headquarters.

For context, Cash App generated $1.8 billion in Bitcoin Ecosystem Revenue in Q2 2026, representing bitcoin buy volume facilitated through the platform. Bitcoin-related revenue accounted for 45% of Cash App revenue for the three months ending March 31, 2026.

The Charter Scorecard: Who Has What

The crypto-native federal banking landscape, as of September 2026:

Final Approval:

  • Circle — First National Digital Currency Bank, N.A. (effective July 10, 2026). First crypto-native firm to complete the full OCC charter process. Authorized to issue stablecoins, custody digital assets, and manage reserves.

Conditional Approval:

  • Ripple National Trust Bank (December 2025)
  • BitGo Bank & Trust, N.A. — conversion from state trust company (December 2025)
  • Paxos Trust Company, N.A. — conversion (December 2025)
  • Fidelity Digital Assets — conversion (December 2025)
  • Bridge / Stripe — stablecoin issuance and digital asset custody (February 2026)
  • Protego (February 2026)
  • Crypto.com / Foris Dax National Trust Bank — custody and staking services (February 2026)
  • World Liberty Trust Company — conditional approval despite opposition from lawmakers and bank trade groups

Pending:

  • Block / Builders Bank & Trust, N.A. (filed September 8, 2026)
  • 12 additional pending applications in the OCC digital-asset pipeline

The national trust bank charter permits custody, fiduciary services, and trust administration. It does not permit deposit-taking, lending, or FDIC-insured banking. This distinction is central to the legal and regulatory contest now unfolding.

Economics: Why Fintechs Want Federal Charters

The financial logic is straightforward. A national trust bank charter replaces a patchwork of up to 50 state money-transmitter licenses, which collectively cost between $500,000 and $2 million to obtain and maintain, according to industry estimates from licensing consultants. Annual renewal costs run approximately $150,000 across all states.

But license fees are the minor cost. The larger economic incentive lies in eliminating third-party dependencies. Block currently routes banking functions through sponsor-bank partnerships and third-party clearing arrangements. Each intermediary extracts fees. A federal charter would allow Block to bring digital-asset custody, order execution, and stablecoin settlement in-house, directing fee revenue toward its own earnings rather than partners.

For Block specifically, the numbers are material. The company reported $6.62 billion in total revenue for Q2 2026. Cash App's bitcoin revenue alone was $1.8 billion in the same quarter. Reducing intermediary costs on this volume — even by basis points — translates into meaningful margin improvement.

The pattern extends beyond Block. Circle's charter enables it to manage USDC reserves without relying on banking partners for custody. Bridge's charter gives Stripe direct control over stablecoin issuance infrastructure. In each case, the charter converts a relationship dependency into an owned capability.

The Banking Lobby Pushback

The Bank Policy Institute, which represents the largest U.S. banks, has publicly evaluated filing a lawsuit against the OCC over national trust charters for crypto and fintech firms. As of the most recent reporting, no suit has been filed, but the threat remains active.

BPI's argument centers on three claims: that trust charters allow crypto firms into the financial system without the same controls required of banks; that the OCC's February 2026 rule change — clarifying that national trust banks are not limited to fiduciary activities — expands charter scope beyond congressional intent; and that approval of politically connected applicants, such as World Liberty Financial, undermines regulatory credibility.

State regulators have echoed these concerns. The Conference of State Bank Supervisors has warned that federal trust charters could preempt state oversight frameworks that currently govern money transmission and digital-asset custody.

The OCC's position, articulated in its February 27, 2026 final rule amending 12 CFR 5.20, is that the agency is clarifying existing authority rather than expanding it. The rule states that national trust banks may engage in activities beyond traditional fiduciary functions, provided those activities fall within the scope of the National Bank Act.

Regulatory Architecture: What Changed

Three regulatory developments created the current charter pipeline:

December 2025 Batch Approvals. The OCC's simultaneous conditional approval of five digital-asset-focused trust bank applications signaled institutional readiness to process crypto charters at scale. Prior to this batch, crypto-native federal bank charters were effectively theoretical.

February 2026 Final Rule (12 CFR 5.20). The OCC amended its chartering regulations to clarify that national trust banks are "not limited to fiduciary activities." This removed a key ambiguity that had discouraged applications: whether a trust charter could support activities like stablecoin settlement, digital-asset order execution, and reserve management alongside traditional custody.

SEC Regulation Crypto Assets Proposal. Published August 18, 2026, the SEC's 402-page proposed rule creates two new offering exemptions for crypto assets — a Startup Exemption (up to $5 million over four years) and a tiered Fundraising Exemption modeled on Regulation A (up to $75 million annually). The 60-day comment period closes approximately October 18, 2026. Combined with the OCC's charter framework, this creates parallel regulatory pathways for crypto firms to operate within federal oversight structures.

The net effect: crypto firms now have a defined path to federal banking status, provided they accept OCC supervision, capital requirements, and examination schedules. The question is whether traditional banks can slow or reverse this path through legal action before it becomes the industry standard.

Key Takeaways

  • The OCC has received 40 de novo charter applications in 18 months, versus 48 in the prior 14 years. Crypto and fintech firms account for a significant share.
  • Block's Builders Bank application would create an uninsured national trust bank for bitcoin and stablecoin custody, serving Cash App's estimated 58.5 million users.
  • Circle is the first crypto-native firm to receive final OCC charter approval (July 10, 2026). Eight others hold conditional approvals. Thirteen applications remain pending.
  • The economic driver is fee internalization: replacing sponsor-bank and state-licensing costs with direct federal oversight reduces intermediary extraction.
  • The Bank Policy Institute has weighed legal action against the OCC. No lawsuit has been filed as of mid-September 2026, but the banking lobby's opposition is public and sustained.
  • The OCC's February 2026 rule change (12 CFR 5.20) expanded the scope of trust bank activities beyond traditional fiduciary functions, creating the regulatory basis for the current charter wave.

Conclusion

The OCC charter pipeline represents a structural renegotiation of who qualifies as a financial institution in the United States. Forty applications in 18 months is not a trend; it is a regime change in the relationship between crypto infrastructure and federal banking oversight.

The economic logic favors charter acquisition. Fintechs that custody digital assets through sponsor-bank arrangements pay for access to banking rails they could own outright. The charter eliminates the intermediary. Whether the BPI's threatened lawsuit, or broader congressional action, disrupts this pipeline will depend on whether courts view the OCC's rule clarification as within existing statutory authority or as an expansion requiring legislative approval.

For now, the applications continue arriving. Block's Builders Bank filing — a $6.62-billion-revenue company seeking to bring bitcoin custody under direct federal supervision — illustrates both the scale and the stakes.

Sources & References

  1. Block Makes a Federal Trust Bank Move That Could Reshape Its Fintech Model — Yahoo Finance, September 2026
  2. Fintechs asking for, and receiving, bank charters in 2026 — American Banker, 2026
  3. Block seeks OCC bank charter — Banking Dive, September 2026
  4. OCC Crypto Bank Charter Pipeline Expands to 13 Pending Applications — CryptoNexa, 2026
  5. Eleven Companies, Eighty-Three Days: The Race for a Federal Crypto Banking License — FinTech Weekly, 2026
  6. US banking lobby weighs lawsuit against OCC over crypto, fintech national trust charters — The Block, 2026
  7. Block Files OCC Application for Digital Asset Trust Bank — CryptoTimes, September 2026
  8. OCC Conditionally Approves Five National Trust Bank Charter Applications — Steptoe, 2025
  9. The New FinTech Scorecard Starts With a Bank Charter — PYMNTS, 2026
  10. Block Provides Preliminary Q2 2026 Cash App Bitcoin Ecosystem Revenue — MarketScreener, 2026